EIN: 581249683
UEI: DUV8VM6Y9ZD1
Audited by: CHERRY BEKAERT LLP
Oversight agency: 84 [Department of Education]
View federal awards & risk assessment →
Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 16, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 16, 2026 (109 days from today).
What is a management decision? →FAC accepted this audit on June 25, 2025 — management decision was due December 25, 2025.
FAC accepted this audit on July 2, 2024 — management decision was due January 2, 2025.
Finding 2023-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster – Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Nonmaterial Noncompliance, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes – 2022-001, 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (“NSLDS”). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student’s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student’s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government’s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: Enrollment information was not properly submitted to NSLDS during 2023. QUESTION COSTS: None noted. CAUSE: The School did not properly implement the corrective action plan from the prior year audit until April 2024. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar’s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT’S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). We worked diligently to resolve these issues with assistance from Anthology and the National Student Clearinghouse. All the reporting configuration issues that prevented timely and accurate reporting have been resolved and verified by the National Student Clearinghouse and on April 16, 2024, we were officially partnered with the Clearinghouse. On that date the Registrar, Financial Aid Manager, and Associate Vice President of Education attended a 2-hour training session, which covered proper reporting procedures and resolving error reports. The College has implemented a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College’s SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College’s SIS listing the last date of attendance for drops and withdrawals, leaves of absence, and standard periods of non-enrollment and upload to the National Student Clearinghouse with subsequent transmission to NSLDS monthly. Submitting the report will be a joint venture between the Registrar, the Financial Aid Manager, and the Associate Vice President of Education. As an internal control, seven days after each scheduled submission, the Associate Vice President of Education will review the submission and any error reports and verify that the enrollment reporting for this period is complete. Enrollment reporting status will be reported as an agenda item at all bi-weekly operations meetings. To ensure timely reporting, all will receive transmission and error reports, and submission dates will be set on outlook calendars as a constant reminder.
Show full finding ▾Hide full finding ▴Finding 2023-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster – Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Nonmaterial Noncompliance, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes – 2022-001, 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (“NSLDS”). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student’s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student’s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government’s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: Enrollment information was not properly submitted to NSLDS during 2023. QUESTION COSTS: None noted. CAUSE: The School did not properly implement the corrective action plan from the prior year audit until April 2024. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar’s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT’S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). We worked diligently to resolve these issues with assistance from Anthology and the National Student Clearinghouse. All the reporting configuration issues that prevented timely and accurate reporting have been resolved and verified by the National Student Clearinghouse and on April 16, 2024, we were officially partnered with the Clearinghouse. On that date the Registrar, Financial Aid Manager, and Associate Vice President of Education attended a 2-hour training session, which covered proper reporting procedures and resolving error reports. The College has implemented a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College’s SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College’s SIS listing the last date of attendance for drops and withdrawals, leaves of absence, and standard periods of non-enrollment and upload to the National Student Clearinghouse with subsequent transmission to NSLDS monthly. Submitting the report will be a joint venture between the Registrar, the Financial Aid Manager, and the Associate Vice President of Education. As an internal control, seven days after each scheduled submission, the Associate Vice President of Education will review the submission and any error reports and verify that the enrollment reporting for this period is complete. Enrollment reporting status will be reported as an agenda item at all bi-weekly operations meetings. To ensure timely reporting, all will receive transmission and error reports, and submission dates will be set on outlook calendars as a constant reminder.
Audit Finding Number: 2023-001-Enrollment Reporting: Management concurs with the finding. The College submitted enrollment reports over the past year according to our approved submission schedule, but the reports were rejected due to configuration issues with our student information system (SIS). We worked diligently to resolve these issues with assistance from Anthology and the National Student Clearinghouse. All the reporting configuration issues that prevented timely and accurate reporting have been resolved and verified by the National Student Clearinghouse. The College has implemented a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College's SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College's SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and upload to the National Student Clearinghouse with subsequent transmission to NSLDS monthly. As an internal control, submitting the report will be a joint venture between the Registrar, the Financial Aid Manager, and the Associate Vice President of Education. These individuals have completed all the required training to ensure accurate reporting. To ensure timely reporting, all will receive transmission and error reports, and submission dates will be set on outlook calendars as a constant reminder. Successful report submission will be a required report at the College's bi-weekly operations meeting. William H. Dindy, Associate Vice President of Education
2022-001
FAC accepted this audit on July 13, 2023 — management decision was due January 13, 2024.
Finding 2022-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS?). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: - Four (4) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Four (4) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Twelve (12) began attending the School in 2022, but were not reported prior to the NSLDS outage beginning in July 2022. QUESTION COSTS: None noted. CAUSE: The School did not implement the corrective action plan from the prior year audit until February 2023. Further, the NSLDS was down from July 2022 to February 2023 and as such, the new policies did not fully take effect until after the year-end. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar?s Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government?s NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the NSLDS became available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule.
Show full finding ▾Hide full finding ▴Finding 2022-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2021-001, 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS?). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: - Four (4) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Four (4) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were not reported prior to the NSLDS outage beginning in July 2022. - Twelve (12) began attending the School in 2022, but were not reported prior to the NSLDS outage beginning in July 2022. QUESTION COSTS: None noted. CAUSE: The School did not implement the corrective action plan from the prior year audit until February 2023. Further, the NSLDS was down from July 2022 to February 2023 and as such, the new policies did not fully take effect until after the year-end. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar?s Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government?s NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the NSLDS became available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule.
Audit Finding Number: 2022-001-Enrollment Reporting: Management concurs with the finding. As noted by the auditors, a corrective action plan was established to ensure that timely enrollment data be coordinated between the Registrar's Office and the Financial Aid Office. This plan was developed in August 2022 along with additional corrective actions efforts to ensure that admission and financial aid data was internally audited prior to enrolling a student. As the audit was conducted, it was evident that the corrective action could not be examined for effectiveness and accuracy as the students examined were from periods prior to the implementation of the corrective action plan and then, as noted by the auditors, the government's NSLDS was not working from July 2022-February 2023, so records could not be shared. The corrective action plan was implemented when the HSLDS because available to submit reports in February 2023. Additionally, the Helms College Registrar, Director of Education and Compliance and Financial Aid Manager will complete free enrollment reporting training courses offered by the National Student Clearinghouse, and continue to submit the enrollment status reports to the National Student Clearinghouse according to the required reporting schedule. Luke Schultheis, Executive Vice President of Education 6/13/23
2021-001
FAC accepted this audit on July 20, 2022 — management decision was due January 20, 2023.
Finding 2021-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (NSLDS). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student's attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government's payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student's Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: * Eight (8) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were reported from 84 days to 207 days after the student's withdrawal. * Six (6) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were reported between 65 days and 164 days after the students graduated. * Four (4) students graduated from a diploma program and were properly reported as graduated. These students, however, continued their education in the degree program but continued to be reported as graduated to the NSLDS. QUESTION COSTS: None noted. CAUSE: The Registrar personnel updates changes in the student status in the Registrar?s system. The Student Financial Aid (SFA) personnel then manually updates status changes to the third party, who is contracted to report status changes to the NSLDS. No internal controls are set in place to ensure that the changes in the student status are reported in the Registrar?s system in an accurate and timely manner. It is the School?s responsibility to ensure the accurate changes in the status are received timely by the third party contractor for update. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College?s SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. As an internal control, the Financial Aid Manager will audit the enrollment reports from the College?s SIS, National Student Clearinghouse, and NSLDS to ensure timely reporting of enrollment changes. Audit Results will be forwarded to the Director of Education and Compliance.
Show full finding ▾Hide full finding ▴Finding 2021-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans ALN: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Compliance Finding, Material Weakness in Internal Controls over Compliance Repeat Finding: Yes ? 2020-001, 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (NSLDS). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student's attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government's payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of forty (40) students who received Pell and/or Direct loans during the year, a review of each sampled student's Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: * Eight (8) students withdrew from the School but were not reported to the NSLDS as withdrawn within the 60 days required. The students were reported from 84 days to 207 days after the student's withdrawal. * Six (6) students graduated from the School but were not reported to the NSLDS as graduated with the 60 days required. The students were reported between 65 days and 164 days after the students graduated. * Four (4) students graduated from a diploma program and were properly reported as graduated. These students, however, continued their education in the degree program but continued to be reported as graduated to the NSLDS. QUESTION COSTS: None noted. CAUSE: The Registrar personnel updates changes in the student status in the Registrar?s system. The Student Financial Aid (SFA) personnel then manually updates status changes to the third party, who is contracted to report status changes to the NSLDS. No internal controls are set in place to ensure that the changes in the student status are reported in the Registrar?s system in an accurate and timely manner. It is the School?s responsibility to ensure the accurate changes in the status are received timely by the third party contractor for update. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners (including the registrar office) of the enrollment reporting compliance requirements per the Code of Federal Regulations, 34 CFR 685.309 (b). The School should then implement internal control procedures to first ensure that errors in the Registrar?s system are corrected in a timely manner, and second to ensure that changes in the student statuses are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College?s SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. As an internal control, the Financial Aid Manager will audit the enrollment reports from the College?s SIS, National Student Clearinghouse, and NSLDS to ensure timely reporting of enrollment changes. Audit Results will be forwarded to the Director of Education and Compliance.
Audit Finding Number: 2021-001 - Enrollment Reporting: Management concurs with the finding. The College will implement a process whereby the Registrar reports graduation statuses at the conclusion of each term to the College's SIS for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. The Registrar will create a separate report of students who have completed a program yet are continuing their education at the College. In addition, the Registrar will generate a weekly report from the College's SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office for upload to the National Student Clearinghouse and subsequent transmission to NSLDS. As an internal control, the Financial Aid Manager will audit the enrollment reports from the College's SIS, National Student Clearinghouse, and NSLDS to ensure timely reporting of enrollment changes. Audit Results will be forwarded to the Director of Education and Compliance. Responsible Personnel: Bill Dindy, Director of Education and Compliance; Freda Gaines, Registrar; Gerri Bogan, Financial Aid Manager Anticipated Completion Date: June 30, 2022
2020-001
Finding 2021-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ALN: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2020-002, 2019-003 CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, Expected Family Contribution, and Cost of Attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s Scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of forty (40) Pell awards, there were nineteen (19) awards to students who were enrolled in a term program and twenty-one (21) awards to students who were enrolled in a clock hour program less than an academic year in length. The School?s standard academic year is three terms and 900 credit hours. Review of the sampled Pell awards noted the following exceptions: * Term Program: one (1) award was calculated based on the student?s status as full time though the student was enrolled for ? time. * Clock Hour Program: six (6) students enrolled in clock hour programs were transfer students. Transfer credits were not appropriately used to adjust the Pell award for four (4) of these students. QUESTION COSTS: $2,383 ? over-payments of Pell made to the sampled students in error. CAUSE: There is a lack of full awareness in the need for designing sufficient controls to ensure the Pell Grants are calculated and disbursed accurately. With the prior year finding (2020-002), the SFA office implemented an internal control process to recalculate the Pell Grant awards which were approved by the third party. However, the SFA officer inadvertently excluded the transfer credit hours in their recalculation of adjusting the Pell award, resulting in noncompliance. EFFECTS: Students may receive more or less aid than they are entitled to receive. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners of the specific requirements of Pell grant calculations. The School should reevaluate and strengthen the internal control procedure to ensure that all key inputs such as transfer credits are considered in their recalculation of the Pell award. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure that responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer. As part of the process, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office. The recalculated awards will be stored in a secure file to compare the recalculations to the final disbursement roster. In addition, all financial aid staff members will participate in mandated training sessions to ensure current processes meet required standards.
Show full finding ▾Hide full finding ▴Finding 2021-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ALN: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2020-002, 2019-003 CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, Expected Family Contribution, and Cost of Attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s Scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of forty (40) Pell awards, there were nineteen (19) awards to students who were enrolled in a term program and twenty-one (21) awards to students who were enrolled in a clock hour program less than an academic year in length. The School?s standard academic year is three terms and 900 credit hours. Review of the sampled Pell awards noted the following exceptions: * Term Program: one (1) award was calculated based on the student?s status as full time though the student was enrolled for ? time. * Clock Hour Program: six (6) students enrolled in clock hour programs were transfer students. Transfer credits were not appropriately used to adjust the Pell award for four (4) of these students. QUESTION COSTS: $2,383 ? over-payments of Pell made to the sampled students in error. CAUSE: There is a lack of full awareness in the need for designing sufficient controls to ensure the Pell Grants are calculated and disbursed accurately. With the prior year finding (2020-002), the SFA office implemented an internal control process to recalculate the Pell Grant awards which were approved by the third party. However, the SFA officer inadvertently excluded the transfer credit hours in their recalculation of adjusting the Pell award, resulting in noncompliance. EFFECTS: Students may receive more or less aid than they are entitled to receive. RECOMMENDATIONS: The School should implement internal control procedures that will educate key process owners of the specific requirements of Pell grant calculations. The School should reevaluate and strengthen the internal control procedure to ensure that all key inputs such as transfer credits are considered in their recalculation of the Pell award. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure that responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer. As part of the process, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office. The recalculated awards will be stored in a secure file to compare the recalculations to the final disbursement roster. In addition, all financial aid staff members will participate in mandated training sessions to ensure current processes meet required standards.
Audit Finding Number: 2021-002 - Disbursements to or on Behalf of Students Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure that responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer. As part of the process, the Registrar will generate a weekly report from the College's SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid Office. The recalculated awards will be stored in a secure file to compare the recalculations to the final disbursement roster. In addition, all financial aid staff members will participate in mandated training sessions to ensure current processes meet required standards. Responsible Personnel: Bill Dindy, Director of Education and Compliance; Gerri Bogan Financial Aid Manager; Freda Gaines, Registrar Anticipated Completion Date: June 30, 2022
2020-002
Finding 2021-003 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Return of Title IV Funds Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: In accordance with 34 CFR 668.22, a school is required to determine the earned and unearned Title IV aid a student has earned as of the date the student ceased attendance based on the amount of time the student spent in attendance. The institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines, or should have determined, that the student withdrew. CONDITION: Twelve (12) students who withdrew from the School were tested for compliance with the return of Title IV Funds. * Loans were disbursed to one (1) student?s account after the student?s withdrawal date. The return calculation treated these loans as aid that could have been disbursed, which resulted in no loans earned for a post withdrawal disbursement. As such, the loans that were subsequently disbursed should have been returned. * One (1) Pell return was based on the difference between the amount of Pell allowed for a ? enrollment status as compared to a full time enrollment status. The difference was returned. The calculation, however, did not calculate the amount of Pell earned by the student at the time of withdrawal. This resulted in an additional amount that should have been returned. * In addition to the two returns noted above which were not returned as of the audit testing, funds were returned more than 45 days after the School became aware of four (4) sampled students? withdrawals. These funds were returned between 52 days and 155 days after the withdrawal notice. QUESTION COSTS: $1,978 ? calculated as the two refunds that were not submitted to the Dept. of Education until auditor?s testing. CAUSE: Although the School implemented a secondary review process for the Return of Title IV calculations, the School has no internal controls set in place to ensure that the Title IV funds are returned within 45 days after it determines that the student withdrew. EFFECTS: Federal Aid refunds are inaccurate, as well as required refunds are not submitted or not submitted in a timely manner as required. RECOMMENDATIONS: The School should implement internal control procedures that will educate all key personnel of the compliance requirement of returning the Title IV funds to ED within the required timeframe. The School should reevaluate and strengthen the internal control procedure to first ensure Title IV return calculations are reviewed for correct inputs of information, and second that all returns calculated are returned to ED within the 45 days requirement. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with this finding. The College will implement an improved internal controls procedure to ensure accurate and timely return of Title IV funds. As part of the process, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid and Student Accounts offices. This process will require the Financial Aid and Student Accounts Offices to sign off on all withdrawal forms obtained from the Registrar. All relevant staff will participate in required training to ensure understanding and compliance with all aspects of the requirements related to Return of Title IV funds.
Show full finding ▾Hide full finding ▴Finding 2021-003 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Return of Title IV Funds Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: In accordance with 34 CFR 668.22, a school is required to determine the earned and unearned Title IV aid a student has earned as of the date the student ceased attendance based on the amount of time the student spent in attendance. The institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines, or should have determined, that the student withdrew. CONDITION: Twelve (12) students who withdrew from the School were tested for compliance with the return of Title IV Funds. * Loans were disbursed to one (1) student?s account after the student?s withdrawal date. The return calculation treated these loans as aid that could have been disbursed, which resulted in no loans earned for a post withdrawal disbursement. As such, the loans that were subsequently disbursed should have been returned. * One (1) Pell return was based on the difference between the amount of Pell allowed for a ? enrollment status as compared to a full time enrollment status. The difference was returned. The calculation, however, did not calculate the amount of Pell earned by the student at the time of withdrawal. This resulted in an additional amount that should have been returned. * In addition to the two returns noted above which were not returned as of the audit testing, funds were returned more than 45 days after the School became aware of four (4) sampled students? withdrawals. These funds were returned between 52 days and 155 days after the withdrawal notice. QUESTION COSTS: $1,978 ? calculated as the two refunds that were not submitted to the Dept. of Education until auditor?s testing. CAUSE: Although the School implemented a secondary review process for the Return of Title IV calculations, the School has no internal controls set in place to ensure that the Title IV funds are returned within 45 days after it determines that the student withdrew. EFFECTS: Federal Aid refunds are inaccurate, as well as required refunds are not submitted or not submitted in a timely manner as required. RECOMMENDATIONS: The School should implement internal control procedures that will educate all key personnel of the compliance requirement of returning the Title IV funds to ED within the required timeframe. The School should reevaluate and strengthen the internal control procedure to first ensure Title IV return calculations are reviewed for correct inputs of information, and second that all returns calculated are returned to ED within the 45 days requirement. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with this finding. The College will implement an improved internal controls procedure to ensure accurate and timely return of Title IV funds. As part of the process, the Registrar will generate a weekly report from the College?s SIS listing the last date of attendance for drops/withdrawals, leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid and Student Accounts offices. This process will require the Financial Aid and Student Accounts Offices to sign off on all withdrawal forms obtained from the Registrar. All relevant staff will participate in required training to ensure understanding and compliance with all aspects of the requirements related to Return of Title IV funds.
Audit Finding Number: 2021-003 - Return of Title IV Management concurs with this finding. The College will implement an improved internal controls procedure to ensure accurate and timely return of Title IV funds. As part of the process, the Registrar will generate a weekly report from the College's SIS listing the last date of attendance for drops/withdrawals,leaves of absence, and standard periods of non-enrollment and submit to the Financial Aid and Student Account offices. This process will require the Financial Aid and Student Accounts Offices to sign off on all withdrawal forms obtained from the Registrar. All relevant staff will participate in required training to ensure understanding and compliance with all aspects of the requirements related to Return of Title IV funds. Responsible Personnel: Bill Dindy, Director of Education and Compliance; Gerri Bogan, Financial Aid Manager; Freda Gaines, Registrar; Robie Mills, Student Accounts Manager Anticipated Completion Date: June 30, 2022
Finding 2021-004 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ALN: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Gramm-Leach-Bliley Act Type of Finding: Compliance Finding; Significant Deficiency in Internal Controls over Compliance CRITERIA: The Gramm-Leach-Bliley Act (Public Law 106-102) (GLBA) requires financial institutions and Institutions of Higher Education to explain their information-sharing practices with their customers to safeguard sensitive data (16 CFR 314). Schools must protect student financial information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of student financial aid programs. Schools are required to designate an individual to coordinate the information security program and perform a risk assessment that addresses the required areas noted in 16 CFR 314.4(b) which are 1) employee training and management; 2) information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3) detecting, preventing, and responding to attacks, intrusions, or other system failures. Further, the School must document safeguards for each of the identified risks. CONDITION: The School has performed a high-level assessment for several common information security controls. However, the School has no evidence that it performed the required risk assessment documenting specific risks identified in relation to the Gramm-Leach-Bliley Act, or safeguards to address identified risk. QUESTION COSTS: N/A CAUSE: The School?s information security program does not include procedures for the performance of formally documented regular risk assessments addressing the School?s compliance with GLBA. EFFECTS: Without a completed risk assessment, the School may not maintain adequate safeguards to protect student financial information in compliance with GLBA. Failure to comply with the GLBA standards puts the School at risk that the School?s information and systems could be vulnerable to attacks, and these attacks may not be detected in a timely manner. RECOMMENDATIONS: We recommend the School develop and implement a policy to ensure that required risk assessments are performed on a regular basis, (at least annually) and that safeguards for each identified risk are implemented. Documentation should be retained to support the procedures performed to ensure compliance. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. In partnership with the IT department the College will develop and implement a policy to ensure that risk assessments are performed at least once per year. Any risks identified will be documented and processes, procedures, and safeguards will be created to mitigate future risks.
Show full finding ▾Hide full finding ▴Finding 2021-004 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ALN: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Gramm-Leach-Bliley Act Type of Finding: Compliance Finding; Significant Deficiency in Internal Controls over Compliance CRITERIA: The Gramm-Leach-Bliley Act (Public Law 106-102) (GLBA) requires financial institutions and Institutions of Higher Education to explain their information-sharing practices with their customers to safeguard sensitive data (16 CFR 314). Schools must protect student financial information, with particular attention to information provided to institutions by the Department of Education or otherwise obtained in support of the administration of student financial aid programs. Schools are required to designate an individual to coordinate the information security program and perform a risk assessment that addresses the required areas noted in 16 CFR 314.4(b) which are 1) employee training and management; 2) information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and 3) detecting, preventing, and responding to attacks, intrusions, or other system failures. Further, the School must document safeguards for each of the identified risks. CONDITION: The School has performed a high-level assessment for several common information security controls. However, the School has no evidence that it performed the required risk assessment documenting specific risks identified in relation to the Gramm-Leach-Bliley Act, or safeguards to address identified risk. QUESTION COSTS: N/A CAUSE: The School?s information security program does not include procedures for the performance of formally documented regular risk assessments addressing the School?s compliance with GLBA. EFFECTS: Without a completed risk assessment, the School may not maintain adequate safeguards to protect student financial information in compliance with GLBA. Failure to comply with the GLBA standards puts the School at risk that the School?s information and systems could be vulnerable to attacks, and these attacks may not be detected in a timely manner. RECOMMENDATIONS: We recommend the School develop and implement a policy to ensure that required risk assessments are performed on a regular basis, (at least annually) and that safeguards for each identified risk are implemented. Documentation should be retained to support the procedures performed to ensure compliance. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. In partnership with the IT department the College will develop and implement a policy to ensure that risk assessments are performed at least once per year. Any risks identified will be documented and processes, procedures, and safeguards will be created to mitigate future risks.
Audit Finding Number: 2021-004 - Gramm-Leach Bliley Act Management concurs with the finding. In partnership with the IT department the College will develop and implement a policy to ensure that risk assessments are performed at least once per year. Any risks identified will be documented and processes, procedures, and safeguards will be created to mitigate future risks. Responsible Personnel: Bill Dindy, Director of Education and Compliance; Doug Newsome, Vice President for Administration Anticipated Completion Date: November 30, 2022
Finding 2021-005 Federal Agency: Department of Education Federal Program: Covid-19 Education Stabilization Fund ALN: # 84.425 Compliance Requirement: Reporting Type of Finding: Compliance Finding; Significant Deficiency in Internal Controls over Compliance CRITERIA: There are three components to reporting for HEERF: 1) annual reporting; 2) public reporting on the Institutional Portion; and 3) public reporting on the Student Aid Portion. The Department of Education developed the HEERF Data Collection Form that institutions must use to satisfy the annual reporting. The CARES, CRRSAA, and ARP Institutional Portion quarterly reporting requirements involve publicly posting completed forms on the School?s website. The forms must be conspicuously posted on the School?s primary website. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all Institutional Portion funds and checks the ?final report? box. Schools must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). The Student Aid Portion quarterly reporting requirements involve publicly posting seven specific reporting elements of the Student Aid Portion Award on their website. The reports HEERF I, HEERF II, and HEERF III are to be posted within ten days after the end of every calendar quarter, with each report distinctly specifying the quarterly time frame of each reporting period. The seven reporting elements are as follows: 1) An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds; 2) The total amount of funds that the institution will receive or has received from the Department; 3) The total amount of grants distributed to students; 4) The estimated total number of students at the institution eligible to participate and receive the grant; 5) The total number of students who received the grant; 6) The methods used by the institution to determine which students received the grant and how much they would receive; and, 7) Any instructions or directions provided by the institution to students about the grant. Schools must post their two separate reports (Institutional and Student Aid) for each quarter until they expend all grant funds, including the quarterly reports from previous quarters. Each report is separate for the calendar quarter and is not cumulative. CONDITION: During our testing of reports required in relation to Institutional and Student Aid funds received under the CARES, CRRSAA, and ARP Acts, the School was unable to furnish support corroborating the posting of the required reports to the School's website. At the time of the audit, the information publicly available on the School?s website was over 1 year old. We are aware that during routine updates to the website, the reportings were inadvertently removed and replaced with information that was previously posted. As such, the School was unable to verify that they posted, or posted timely, their initial and quarterly public reports for both the student aid portion and institutional portion on their website. Reporting was reuploaded to the website during the audit. The reporting, however, did not contain all seven of the Student Aid reporting elements, resulting in noncompliance. QUESTION COSTS: N/A CAUSE: As noted above, reports were inadvertently removed from the School?s website. In addition, the School has experienced turnover in multiple staff positions during the year, which led to the absence of consistent and appropriate review processes related to HEERF reporting. EFFECTS: The School is not in compliance with the HEERF reporting requirements. Federal oversight agencies depend on accurate and timely reports to measure program results. RECOMMENDATIONS: We recommend that the School implement a process to ensure all required reporting is being performed accurately and timely and put oversight procedures into practice over this process. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process through which the Director of Education and Compliance ensures the Web and Financial Aid teams are reporting HEERF information in an accurately and timely matter to adhere to published requirements.
Show full finding ▾Hide full finding ▴Finding 2021-005 Federal Agency: Department of Education Federal Program: Covid-19 Education Stabilization Fund ALN: # 84.425 Compliance Requirement: Reporting Type of Finding: Compliance Finding; Significant Deficiency in Internal Controls over Compliance CRITERIA: There are three components to reporting for HEERF: 1) annual reporting; 2) public reporting on the Institutional Portion; and 3) public reporting on the Student Aid Portion. The Department of Education developed the HEERF Data Collection Form that institutions must use to satisfy the annual reporting. The CARES, CRRSAA, and ARP Institutional Portion quarterly reporting requirements involve publicly posting completed forms on the School?s website. The forms must be conspicuously posted on the School?s primary website. A new, separate form must be posted covering aggregate amounts spent for HEERF I, HEERF II, and HEERF III funds each quarterly reporting period (September 30, December 31, March 31, June 30), concluding after an institution has expended and liquidated all Institutional Portion funds and checks the ?final report? box. Schools must post this quarterly report form no later than 10 days after the end of each calendar quarter (October 10, January 10, April 10, July 10). The Student Aid Portion quarterly reporting requirements involve publicly posting seven specific reporting elements of the Student Aid Portion Award on their website. The reports HEERF I, HEERF II, and HEERF III are to be posted within ten days after the end of every calendar quarter, with each report distinctly specifying the quarterly time frame of each reporting period. The seven reporting elements are as follows: 1) An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds; 2) The total amount of funds that the institution will receive or has received from the Department; 3) The total amount of grants distributed to students; 4) The estimated total number of students at the institution eligible to participate and receive the grant; 5) The total number of students who received the grant; 6) The methods used by the institution to determine which students received the grant and how much they would receive; and, 7) Any instructions or directions provided by the institution to students about the grant. Schools must post their two separate reports (Institutional and Student Aid) for each quarter until they expend all grant funds, including the quarterly reports from previous quarters. Each report is separate for the calendar quarter and is not cumulative. CONDITION: During our testing of reports required in relation to Institutional and Student Aid funds received under the CARES, CRRSAA, and ARP Acts, the School was unable to furnish support corroborating the posting of the required reports to the School's website. At the time of the audit, the information publicly available on the School?s website was over 1 year old. We are aware that during routine updates to the website, the reportings were inadvertently removed and replaced with information that was previously posted. As such, the School was unable to verify that they posted, or posted timely, their initial and quarterly public reports for both the student aid portion and institutional portion on their website. Reporting was reuploaded to the website during the audit. The reporting, however, did not contain all seven of the Student Aid reporting elements, resulting in noncompliance. QUESTION COSTS: N/A CAUSE: As noted above, reports were inadvertently removed from the School?s website. In addition, the School has experienced turnover in multiple staff positions during the year, which led to the absence of consistent and appropriate review processes related to HEERF reporting. EFFECTS: The School is not in compliance with the HEERF reporting requirements. Federal oversight agencies depend on accurate and timely reports to measure program results. RECOMMENDATIONS: We recommend that the School implement a process to ensure all required reporting is being performed accurately and timely and put oversight procedures into practice over this process. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process through which the Director of Education and Compliance ensures the Web and Financial Aid teams are reporting HEERF information in an accurately and timely matter to adhere to published requirements.
Audit Finding Number: 2021-005 - HEERF Reporting Management concurs with the finding. The College will implement a process through which the Director of Education and Compliance ensures the Web and Financial Aid teams are reporting HEERF information in an accurately and timely matter to adhere to published requirements. Responsible Personnel: Bill Dindy, Director of Education and Compliance; Gerri Bogan, Financial Aid Manager, Travis Walters, Sr. Manager of Web Strategies and Content Marketing Anticipated Completion Date: Each quarter of 2022
FAC accepted this audit on September 9, 2021 — management decision was due March 9, 2022.
Finding 2020-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans CFDA: # 84.268 Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b), requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS)?. Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of fifty-four (54) students who received financial aid during the year, sixteen (16) students were enrolled and active, seventeen (17) had graduated, and twenty-one (21) had withdrawn. A review of the each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: * Eight (8) enrollment status changes were not reported until student was selected for audit sampling. * Seven (7) additional enrollment status changes were not reported within the 60 day requirement. The reportings were made 66, 69, 69, 71, 77, 105, and 188 days after the student?s enrollment change should have been reported. * One (1) graduated student was never reported as graduated. * Two (2) students graduated from one program and were properly reported as graduated. Both students, however, continued their education in a new program but continued to be reported as graduated. QUESTION COSTS: None noted. CAUSE: The College has contracted with a third party to report student status changes to the NSLDS based on information obtained from the Registrar?s system that is updated by Registrar personnel. This system also allows the Student Financial Aid (?SFA?) personnel to manually update status changes. According to SFA staff, they have experienced system problems that affected the status of students. However, there is no follow-up to ensure the status changes are uploaded to the NSLDS in a timely manner. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government?s payment of interest subsidies. RECOMMENDATIONS: We recommend that the College implement a review process to 1) ensure that errors in the Registrar?s system are corrected in a timely manner and 2) student statuses for those who withdraw or graduate are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third party servicer for subsequent transmission to NSLDS. In addition, bi-weekly reports listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third party servicer for subsequent transmission to NSLDS. As an internal control, monthly the Financial Aid Manager will compare NSLDS status reports to ensure timely reporting of enrollment changes.
Show full finding ▾Hide full finding ▴Finding 2020-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans CFDA: # 84.268 Compliance Requirement: Special Tests and Provisions ? Enrollment Reporting Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2019-002 CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b), requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (?NSLDS)?. Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From a sample of fifty-four (54) students who received financial aid during the year, sixteen (16) students were enrolled and active, seventeen (17) had graduated, and twenty-one (21) had withdrawn. A review of the each sampled student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site noted the following: * Eight (8) enrollment status changes were not reported until student was selected for audit sampling. * Seven (7) additional enrollment status changes were not reported within the 60 day requirement. The reportings were made 66, 69, 69, 71, 77, 105, and 188 days after the student?s enrollment change should have been reported. * One (1) graduated student was never reported as graduated. * Two (2) students graduated from one program and were properly reported as graduated. Both students, however, continued their education in a new program but continued to be reported as graduated. QUESTION COSTS: None noted. CAUSE: The College has contracted with a third party to report student status changes to the NSLDS based on information obtained from the Registrar?s system that is updated by Registrar personnel. This system also allows the Student Financial Aid (?SFA?) personnel to manually update status changes. According to SFA staff, they have experienced system problems that affected the status of students. However, there is no follow-up to ensure the status changes are uploaded to the NSLDS in a timely manner. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government?s payment of interest subsidies. RECOMMENDATIONS: We recommend that the College implement a review process to 1) ensure that errors in the Registrar?s system are corrected in a timely manner and 2) student statuses for those who withdraw or graduate are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third party servicer for subsequent transmission to NSLDS. In addition, bi-weekly reports listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third party servicer for subsequent transmission to NSLDS. As an internal control, monthly the Financial Aid Manager will compare NSLDS status reports to ensure timely reporting of enrollment changes.
Audit Finding Number: Finding 2020-001- Enrollment Reporting Auditee's Response: The College concurs with Finding 2020-001. Correction Action Plan: The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. In addition, a weekly report listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. As an internal control, the Financial Aid Manager will compare NSLDS to enrollment status reports submitted by the third-party servicer to the National Student Clearinghouse to ensure timely reporting of enrollment changes. Beginning October 2021, the College is implementing a new integrated student information system which has exclusive fields to ensure enrollment reporting accuracy. Responsible Person, Title: Freda Gaines, Registrar Responsible Person, Title: Gerri Bogan, Financial Aid Manager Anticipated Completion Date: October 1, 2021
2019-002
Finding 2020-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: #84.063 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2019-003 CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, expected family contribution, and cost of attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of fifty-two (52) Pell awards, there were thirty-six (36) awards to students who were enrolled in a term program and sixteen (16) awards to students who were enrolled in a clock hour program. The school?s standard academic year is three terms and 900 credit hours. Review of the sampled Pell awards noted the following exceptions: * Two (2) awards were calculated using the 19/20 Pell Payment Schedule rather than the 20/21 Pell Payment Schedule. This resulted in each student receiving $100 less than the amount they were eligible to receive. * Two (2) awards were calculated based on the students? status as full-time though the students were enrolled for ? time. This resulted in over-awards of $529 and $249. * Pell calculations for students enrolled in clock hour programs must be prorated and must use the smaller of hours or weeks proration. One (1) award did not use the lesser of the proration resulting in an overaward of $33. * One (1) award was calculated by reducing the clock hours used for the calculation by 8 transfer credits rather than by 99 transfer hours. This resulted in an over-award of $642. * One (1) Pell payment was drawn twice in error resulting in an over-payment of $2,065. * Five (5) Pell disbursements were made in amounts which could not be supported. Recalculation of these awards resulted in four under-payments to students totaling $615 and one over-payment in the amount of $321. QUESTION COSTS: $3,024 ? calculated as $3,839 over-payments and $815 under-payments of Pell made to the sampled students in error. CAUSE: The School relies on a third party contractor to process aid based on inputs from the Student Financial Aid Office. There are no controls in place to ensure the aid is processed correctly. EFFECTS: Students may receive more or less aid than they are entitled to receive. RECOMMENDATIONS: The use of a third party contractor does not alleviate the School of ensuring aid is packaged correctly. We recommend the College develop and implement policies, procedures and controls to ensure awards are made in compliance with the federal requirements. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer.
Show full finding ▾Hide full finding ▴Finding 2020-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: #84.063 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance Repeat Finding: Yes ? 2019-003 CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, expected family contribution, and cost of attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of fifty-two (52) Pell awards, there were thirty-six (36) awards to students who were enrolled in a term program and sixteen (16) awards to students who were enrolled in a clock hour program. The school?s standard academic year is three terms and 900 credit hours. Review of the sampled Pell awards noted the following exceptions: * Two (2) awards were calculated using the 19/20 Pell Payment Schedule rather than the 20/21 Pell Payment Schedule. This resulted in each student receiving $100 less than the amount they were eligible to receive. * Two (2) awards were calculated based on the students? status as full-time though the students were enrolled for ? time. This resulted in over-awards of $529 and $249. * Pell calculations for students enrolled in clock hour programs must be prorated and must use the smaller of hours or weeks proration. One (1) award did not use the lesser of the proration resulting in an overaward of $33. * One (1) award was calculated by reducing the clock hours used for the calculation by 8 transfer credits rather than by 99 transfer hours. This resulted in an over-award of $642. * One (1) Pell payment was drawn twice in error resulting in an over-payment of $2,065. * Five (5) Pell disbursements were made in amounts which could not be supported. Recalculation of these awards resulted in four under-payments to students totaling $615 and one over-payment in the amount of $321. QUESTION COSTS: $3,024 ? calculated as $3,839 over-payments and $815 under-payments of Pell made to the sampled students in error. CAUSE: The School relies on a third party contractor to process aid based on inputs from the Student Financial Aid Office. There are no controls in place to ensure the aid is processed correctly. EFFECTS: Students may receive more or less aid than they are entitled to receive. RECOMMENDATIONS: The use of a third party contractor does not alleviate the School of ensuring aid is packaged correctly. We recommend the College develop and implement policies, procedures and controls to ensure awards are made in compliance with the federal requirements. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer.
Audit Finding Number: Finding 2020-002 - Disbursements to or on Behalf of Students Auditee's Response: The College concurs with Finding 2020-002. Correction Action Plan: The Financial Aid Office will implement a process of recalculating Pell Grant awards approved by the third-party servicer. The process will occur monthly and provide internal control to ensure responsibility for accurate Pell Grant awarding rests with the Financial Aid Office rather than the third-party servicer. Beginning November 2021, the College is implementing a new integrated system for financial aid processing services to ensure satisfaction of all regulatory student eligibility requirements. Responsible Person, Title: Aleathea Walker, Financial Aid Advisor Responsible Person, Title: Gerri Bogan, Financial Aid Manager Anticipated Completion Date: November 1, 2021
2019-003
FAC accepted this audit on December 30, 2020 — management decision was due June 30, 2021.
Finding 2019-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Return of Title IV Funds Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: In accordance with 34 CFR 668.22, a school is required to determine the earned and unearned Title IV aid a student has earned as of the date the student ceased attendance based on the amount of time the student spent in attendance. The institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines, or should have determined, that the student withdrew. CONDITION: We obtained a listing of all students who withdrew from the school during the year. We compared this listing to the listing of students who received federal aid during the school year. This resulted in one hundred and five (105) students who withdrew from the College during the year who had been awarded federal financial aid. We also noted students who were not on the list of withdrawn students who appeared to have withdrawn as they were listed as dropped on the detail of students who received aid during the year. We sampled eleven (11) of the students on the withdrawn list and six (6) students who were not on the withdrawn list but noted as dropped. Our testing of these seventeen (17) students resulted in the following findings: 1. We noted eight (8) of the sampled students completed more than 60% of the term, thus no refund was required. 2. We noted two (2) of the sampled students did not receive aid for the term in which the students withdrew, thus no refund was required. 3. We noted eight (8) of the sampled students completed less than 60% of the term in which they received federal aid, thus requiring a refund. Of these 8 refunds, four (4) were returned after the 45 day requirement. These returns were made 49, 88, 137, and 204 days after the student was determined to be withdrawn. 4. We noted two (2) students who withdrew during a term had subsequently received aid for the following term in which the student was not enrolled. This aid, which consisted of $3,134 unsubsidized loans and $2,031 Pell grant, was received 30 days and 109 days after the students withdrew. The unallowable aid was not returned until both students were sampled in the audit. 5. We noted one (1) return calculation used the incorrect Pell amount received. The incorrect amount resulted in a shortage of $232 that was not returned 6. We noted two (2) return calculations used the incorrect Institutional charges when determining the amount of federal funds the College should return. The incorrect charges had no effect on the results of the return calculations. QUESTION COSTS: $5,397 ? calculated as the two refunds that were not submitted to the Dept. of Education until auditor?s inquiry in addition to the amount refunded based on using the incorrect amount of aid drawn. CAUSE: The College has contracted with a third party to process the returns of aid when a student withdraws. The College provides the third party contractor with the information needed to calculate the return, which includes the student?s transcripts, AR Ledger, attendance record, and withdrawal form. We noted this information appears to be uploaded to the contractor in a timely manner. However, there is no follow-up to ensure the return calculations are completed. There is also no review to ensure the calculations are completed accurately. EFFECTS: Federal Aid refunds are inaccurate, as well as required refunds are not submitted or not submitted in a timely manner as required. RECOMMENDATIONS: We recommend the College develop and implement policies, procedures and controls to ensure that Title IV return calculations are reviewed for correct inputs of information and that all returns calculated are returned to the Dept. of Education within the required time. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a secondary review process for the Return of Title IV Calculations performed by the third-party servicer. The process will provide internal control and ensure responsibility for accurate calculations and timely return of funds rests with the secondary reviewer rather than the third-party servicer.
Show full finding ▾Hide full finding ▴Finding 2019-001 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Return of Title IV Funds Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: In accordance with 34 CFR 668.22, a school is required to determine the earned and unearned Title IV aid a student has earned as of the date the student ceased attendance based on the amount of time the student spent in attendance. The institution must return the amount of Title IV funds for which it is responsible as soon as possible, but no later than 45 days after it determines, or should have determined, that the student withdrew. CONDITION: We obtained a listing of all students who withdrew from the school during the year. We compared this listing to the listing of students who received federal aid during the school year. This resulted in one hundred and five (105) students who withdrew from the College during the year who had been awarded federal financial aid. We also noted students who were not on the list of withdrawn students who appeared to have withdrawn as they were listed as dropped on the detail of students who received aid during the year. We sampled eleven (11) of the students on the withdrawn list and six (6) students who were not on the withdrawn list but noted as dropped. Our testing of these seventeen (17) students resulted in the following findings: 1. We noted eight (8) of the sampled students completed more than 60% of the term, thus no refund was required. 2. We noted two (2) of the sampled students did not receive aid for the term in which the students withdrew, thus no refund was required. 3. We noted eight (8) of the sampled students completed less than 60% of the term in which they received federal aid, thus requiring a refund. Of these 8 refunds, four (4) were returned after the 45 day requirement. These returns were made 49, 88, 137, and 204 days after the student was determined to be withdrawn. 4. We noted two (2) students who withdrew during a term had subsequently received aid for the following term in which the student was not enrolled. This aid, which consisted of $3,134 unsubsidized loans and $2,031 Pell grant, was received 30 days and 109 days after the students withdrew. The unallowable aid was not returned until both students were sampled in the audit. 5. We noted one (1) return calculation used the incorrect Pell amount received. The incorrect amount resulted in a shortage of $232 that was not returned 6. We noted two (2) return calculations used the incorrect Institutional charges when determining the amount of federal funds the College should return. The incorrect charges had no effect on the results of the return calculations. QUESTION COSTS: $5,397 ? calculated as the two refunds that were not submitted to the Dept. of Education until auditor?s inquiry in addition to the amount refunded based on using the incorrect amount of aid drawn. CAUSE: The College has contracted with a third party to process the returns of aid when a student withdraws. The College provides the third party contractor with the information needed to calculate the return, which includes the student?s transcripts, AR Ledger, attendance record, and withdrawal form. We noted this information appears to be uploaded to the contractor in a timely manner. However, there is no follow-up to ensure the return calculations are completed. There is also no review to ensure the calculations are completed accurately. EFFECTS: Federal Aid refunds are inaccurate, as well as required refunds are not submitted or not submitted in a timely manner as required. RECOMMENDATIONS: We recommend the College develop and implement policies, procedures and controls to ensure that Title IV return calculations are reviewed for correct inputs of information and that all returns calculated are returned to the Dept. of Education within the required time. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a secondary review process for the Return of Title IV Calculations performed by the third-party servicer. The process will provide internal control and ensure responsibility for accurate calculations and timely return of funds rests with the secondary reviewer rather than the third-party servicer.
Audit Finding Number: Finding 2019-001 Auditee's Response: The College concurs with Finding 2019-001. Correction Action Plan: The College will implement a secondary review process for the Return of Title IV calculations performed by the third-party servicer. The process will provide internal control and ensure responsibility for accurate calculations and timely return of funds rests with the secondary reviewer rather than the third-party servicer. Responsible Person, Title: Robie Mills, Student Accounts Manager Anticipated Completion Date: September 1, 2020
Finding 2019-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans CFDA: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (NSLDS). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From the seventeen (17) students sampled and tested for Return of Title IV Funds in finding 2019-001 above, we reviewed the student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site. Of the 17 withdrawn students sampled, we noted a delay in reporting the withdrawn status for four (4) of the sampled students. The status change was reported 62, 84, 222, and 332 days after the student was determined to be withdrawn. The two (2) most delinquent status changes were not reported until the student was selected for audit testing. In addition, we also noted discrepancies between the student?s withdrawal date and the effective date reported to the NSLDS for two (2) sampled students. The withdrawal effective dates were reported as 13 and 14 days after the students? actual withdrawal. Both effective dates were reported as the date the withdrawal forms were completed and not the student?s last day of attendance. QUESTION COSTS: None noted. CAUSE: The College has contracted with a third party to report student status changes to the NSLDS based on information obtained from the Registrar?s system that is updated by Registrar personnel. This system also allows the Student Financial Aid (?SFA?) personnel to manually update status changes. According to SFA staff, they have experienced system problems that affected the status of students. However, there is no follow-up to ensure the status changes are uploaded to the NSLDS in a timely manner. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: We recommend the College implement a review process to 1) ensure that errors in the Registrar?s system are corrected in a timely manner and 2) student statuses for those who withdraw or graduate are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. In addition, bi-weekly reports listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. As an internal control, monthly the Financial Aid Manager will compare NSLDS status reports to ensure timely reporting of enrollment changes. The College also has approval to replace its Student Information System. Data conversion will begin Fall 2020. This will reduce erroneous and untimely enrollment reporting and eliminate manual system uploads.
Show full finding ▾Hide full finding ▴Finding 2019-002 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster ? Federal Direct Student Loans CFDA: # 84.268 Compliance Requirement: Special Tests and Provisions - Enrollment Reporting Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: The Code of Federal Regulations, 34 CFR 685.309 (b) requires Schools to certify and report the enrollment status of students who receive Title IV aid to the National Student Loan Data System (NSLDS). Enrollment status changes for students must be reported to NSLDS within 30 days or within 60 days if the student with the status change will be reported on a scheduled transmission within 60 days of the change in status. Regulations require the status include an accurate effective date. Enrollment information must be reported whenever a student?s attendance pattern changes. These changes include reductions or increases in attendance levels, withdrawals, graduations, or approved leaves-of-absence. This enrollment information is merged to the NSLDS database and reported to the guarantors, lenders, and servicers of student loans. A student?s enrollment status determines deferment eligibility, grace periods, and repayment schedules, as well as the government?s payment of interest subsidies. As such, NSLDS records must be accurately matched with enrollment records. Schools must continually review, update, and verify student enrollment statuses and other information. CONDITION: From the seventeen (17) students sampled and tested for Return of Title IV Funds in finding 2019-001 above, we reviewed the student?s Enrollment Data as updated to the NSLDS system per the NSLDS web-site. Of the 17 withdrawn students sampled, we noted a delay in reporting the withdrawn status for four (4) of the sampled students. The status change was reported 62, 84, 222, and 332 days after the student was determined to be withdrawn. The two (2) most delinquent status changes were not reported until the student was selected for audit testing. In addition, we also noted discrepancies between the student?s withdrawal date and the effective date reported to the NSLDS for two (2) sampled students. The withdrawal effective dates were reported as 13 and 14 days after the students? actual withdrawal. Both effective dates were reported as the date the withdrawal forms were completed and not the student?s last day of attendance. QUESTION COSTS: None noted. CAUSE: The College has contracted with a third party to report student status changes to the NSLDS based on information obtained from the Registrar?s system that is updated by Registrar personnel. This system also allows the Student Financial Aid (?SFA?) personnel to manually update status changes. According to SFA staff, they have experienced system problems that affected the status of students. However, there is no follow-up to ensure the status changes are uploaded to the NSLDS in a timely manner. EFFECTS: Inaccurate and delayed submission of student enrollment status information affects the determinations that lenders and servicers of student loans make related to in-school status, grace periods, repayment schedules, and deferments. It also affects the federal government's payment of interest subsidies. RECOMMENDATIONS: We recommend the College implement a review process to 1) ensure that errors in the Registrar?s system are corrected in a timely manner and 2) student statuses for those who withdraw or graduate are reported within the required timeframe. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. In addition, bi-weekly reports listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. As an internal control, monthly the Financial Aid Manager will compare NSLDS status reports to ensure timely reporting of enrollment changes. The College also has approval to replace its Student Information System. Data conversion will begin Fall 2020. This will reduce erroneous and untimely enrollment reporting and eliminate manual system uploads.
Audit Finding Number: Finding 2019-002 Auditee's Response: The College concurs with Finding 2019-002. Correction Action Plan: The College will implement a process of reporting graduation statuses at the conclusion of each term to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. In addition, bi-weekly reports listing the last date of attendance for drops/withdrawals, leave of absences, and standard periods of non-enrollment will be submitted to the Financial Aid Office for manual system upload to the third-party servicer for subsequent transmission to NSLDS. As an internal control, monthly the Financial Aid Manager will compare NSLDS status reports to ensure timely reporting of enrollment changes. The College has approval to replace its Student Information System; data conversion will begin Fall 2020. This will reduce erroneous and untimely enrollment reporting and eliminate manual system uploads. Responsible Person, Title: Freda Gaines, Registrar Responsible Person, Title: Gerri Bogan, Financial Aid Manager Anticipated Completion Date: September 1, 2020
Finding 2019-003 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, Expected Family Contribution, and Cost of Attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s Scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of forty (40) students who received federal financial aid, there were twenty-three (23) students who received Pell who were enrolled in a term program and sixteen (16) students who received Pell who were enrolled in a clock hour program. The School?s standard academic year is three terms and 900 credit hours. Review of the sampled students? Pell awards noted the following exceptions: 1. Three students enrolled in term programs were disbursed Pell based on two (2) terms rather than three (3). The annual Pell award was divided into 2 payment periods resulting in an overpayment for those payment periods. 2. One of these students also received Pell for a third payment term in the amount of one-fourth of the annual award. 3. One student enrolled in a term program received Pell grant funds based on full-time enrollment. The student was only enrolled half time, resulting in an overpayment. 4. One student enrolled in a clock hour program that is less than an academic year received Pell grant funds based on a full academic year. 5. For another student, Pell grant funds were calculated using the student?s 18/19 Expected Family Contribution (?EFC?) rather than the 19/20 EFC. QUESTION COSTS: $5,345 ? calculated as overpayments of Pell made to the sampled students in error. CAUSE: The School relies on a third party contractor to process aid based on inputs from the Student Financial Aid Office. There are no controls in place to ensure the aid is processed correctly. EFFECTS: Students may receive more aid than they are entitled to receive. RECOMMENDATIONS: The use of a third party contractor does not alleviate the School of ensuring aid is packaged correctly. We recommend the College develop and implement policies, procedures and controls to ensure awards are made in compliance with the federal requirements. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer.
Show full finding ▾Hide full finding ▴Finding 2019-003 Federal Agency: Department of Education Federal Program: Student Financial Aid Cluster CFDA: # 84.007, 84.033, 84.063, 84.268 Compliance Requirement: Special Tests and Provisions ? Disbursements to or on Behalf of Students Type of Finding: Significant Deficiency in Internal Controls over Compliance CRITERIA: Each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment and Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, Expected Family Contribution, and Cost of Attendance. Once the annual award is determined, the institution must calculate the payment for the payment periods. For credit-hour term based programs, the term is the payment period. For clock hour programs which are less than an academic year in length, the calculation for the payment period prorates a student?s Scheduled award based on the lesser of the number of clock hours in the payment period as compared to the clock hours in the defined academic year, or the number of weeks of instructional time in the payment period as compared to the weeks of instructional time in the academic year. CONDITION: From the sample of forty (40) students who received federal financial aid, there were twenty-three (23) students who received Pell who were enrolled in a term program and sixteen (16) students who received Pell who were enrolled in a clock hour program. The School?s standard academic year is three terms and 900 credit hours. Review of the sampled students? Pell awards noted the following exceptions: 1. Three students enrolled in term programs were disbursed Pell based on two (2) terms rather than three (3). The annual Pell award was divided into 2 payment periods resulting in an overpayment for those payment periods. 2. One of these students also received Pell for a third payment term in the amount of one-fourth of the annual award. 3. One student enrolled in a term program received Pell grant funds based on full-time enrollment. The student was only enrolled half time, resulting in an overpayment. 4. One student enrolled in a clock hour program that is less than an academic year received Pell grant funds based on a full academic year. 5. For another student, Pell grant funds were calculated using the student?s 18/19 Expected Family Contribution (?EFC?) rather than the 19/20 EFC. QUESTION COSTS: $5,345 ? calculated as overpayments of Pell made to the sampled students in error. CAUSE: The School relies on a third party contractor to process aid based on inputs from the Student Financial Aid Office. There are no controls in place to ensure the aid is processed correctly. EFFECTS: Students may receive more aid than they are entitled to receive. RECOMMENDATIONS: The use of a third party contractor does not alleviate the School of ensuring aid is packaged correctly. We recommend the College develop and implement policies, procedures and controls to ensure awards are made in compliance with the federal requirements. MANAGEMENT?S RESPONSE AND CORRECTIVE ACTION PLAN: Management concurs with the finding. The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer.
Audit Finding Number: Finding 2019-003 Auditee's Response: The College concurs with Finding 2019-003. Correction Action Plan: The Financial Aid Office will implement a review process of Pell Grant awards approved by the third-party servicer. The review process will occur prior to disbursement and immediately following changes in enrollment status. The process will provide internal control and ensure responsibility for accurate Pell Grant awards rests with the Financial Aid Office rather than the third-party servicer. Responsible Person, Title: Gerri Bogan, Financial Aid Manager Responsible Person, Title: Angela Bussey, Financial Aid Advisor Anticipated Completion Date: September 1, 2020
FAC accepted this audit on June 27, 2019 — management decision was due December 27, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2017-001
FAC accepted this audit on July 2, 2018 — management decision was due January 2, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2016-002
FAC accepted this audit on June 21, 2017 — management decision was due December 21, 2017.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
2015-001
GSA_MIGRATION
Show full finding ▾Hide full finding ▴GSA_MIGRATION
GSA_MIGRATION
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
Track your findings and corrective action plans across audit cycles.
Start tracking findings →Monitor subrecipient audit findings and filing records.
Start monitoring →© 2026 Single Audit Intelligence. All data is public domain.
